During the January 13, 2022 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed how load calculation can help foster reliable operational forecasting and efficient market settlements under O2222. Stakeholder feedback is requested on the proposed approach.
Please provide feedback by January 27.
WPPI found the discussion of load calculation with DEARs (DER aggregators) at the DERTF on 1/13 (agenda item 5) very informative. We offer the following comments/questions on MISO’s proposed approach to load calculation:
(1.) The load calculation process for an LSE (WPPI’s perspective) seems relatively straightforward in the case of a DEAR (aggregation of DERs) that consists only of generators (DEAR1).
(2.) What’s less clear to us is how to manage the load calculation ***process*** as an LSE in the case of a DEAR that includes demand response. For example, suppose DEAR2 consists only of demand response and affects a WPPI load EPNode in LBA X.
(a.) As an LSE, whether we address the effect of DEAR2 on WPPI’s load EPNode in LBA X depends on whether DEAR’s 2 Real-time Ex Post LMP is less/greater (address/don’t address) than the Net Benefit Price Threshold. While the NBPT is provided before the start of each month, (Q1) currently, when does MISO post Real-time Ex Post LMPs in a format accessible for download? (In order for WPPI to send the relevant SCADA data to LBA X, we need to know whether the LMP is less/greater than the NBPT for each hour of an operating day within 30 minutes after the end of the operating day.)
(b.) In order for WPPI to meet its obligation to LBA X, WPPI will need access to DEAR2’s SCADA data (as was the case for DEAR1), which is an estimate of the load reduction DEAR2 is providing (vs. DEAR1, output is directly measured).
(c.) (Q2a) How soon will MISO’s measurement and verification of the demand reduction provided by DEAR2 be complete and (Q2b) how will WPPI obtain that data in order to provide the necessary data for settlements?
(3.) Given how DEAR generator vs. demand response data are handled in MISO settlements, in the case of a DEAR with some of each, it will be necessary for there to be separate SCADA streams for each and it will be necessary to have separate final MWh for each.
(4.) (Q3) Is the load calculation for an Electric Storage Resource on a distribution system the same as that being proposed for a DEAR?
MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – LOAD CALCULATION WITH DISTRIBUTED ENERGY AGGREGATED RESOURCE (DEAR)
DATE: JANUARY 27, 2022
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the January 13, 2022, Distributed Energy Resource Task Force (DERTF) meeting concerning the FERC Order 2222 filing framework and the related topic of load calculation with Distributed Energy Aggregated Resource (DEAR).
Fundamentally, the EOC’s agree that additional data in the form of telemetry on every DEAR could be helpful in many respects, including improvements in the Local Balancing Authority’s (LBA) calculation of real time load. However, this requirement may have the effect of blocking new entrants as well as the incurrence of significant expense in the form of Distributed Energy Resource Management System (DERMS). Due to these concerns, the potential for initial low DEAR penetration and the need to involve the Relevant Electric Retail Regulatory Authorities (RERRA) in these decisions, the EOC’s think that this requirement should be delayed for now.
For settlements, the EOC’s think that the use of meter data would be the most prudent, and that measuring demand response is achievable with the use of Advanced Metering Infrastructure.
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
Consumers Energy appreciates the opportunity to provide feedback regarding MISO's proposed approach regarding load calculation and operational forecasting and market settlement under O2222 as presented at the January 13, 2022 DERTF. CE generally supports MISO's proposed approach that all DEAR volumes should be telemetered to MISO & LBA and included in LSE reported volumes.
On behalf of Ameren Corporation I am submitting the below feedback.
As discussed in the feedback above for the Chestnut use case, there are many concepts and questions that should be more fully explored to understand their implications prior to reaching a final proposed approach for this topic. We understand that MISO is currently suggesting that requirements of BPM 031 would not apply to an individual resources, only to the aggregations. However, this approach raises additional questions. How will the aggregators obtain the data that they need to provide telemetry for their programs, and whether this same data will be used for settlements? What metering, algorithm, estimating protocol, etc. will they use? What role, if any, will Ameren's own metering play in this. Will aggregators require access to Ameren owned metering to perform this? Will MISO follow the path in California to allow aggregations to deploy their own submetering, or estimation methodologies and how would the results of this effort be reconciled for settlement with Ameren metering? There are additional implications and questions that should be discussed specifically within the taskforce on this topic prior to imposing new requirements surrounding this topic for DEAR’s or DERA’s in this process so the implications of these requirements can be fully understood and vetted by the stakeholders and then appropriately documented in this process.
DTE agrees with MISO’s proposed approach to require all DEAR volumes telemetered to MISO. MISO should design DEAR meter data submission process that allows EDCs’ validation of meter data submittals for market nodes in their service territories.